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Health and Safety

Executive

The Importance of Safe


Isolation of
Plant and Equipment

Graeme Hughes HID CI 1G


HM Specialist Inspector (Mechanical)
Background to HS(G) 253

• Issue of guidance in January 2006.


• Widening out scope of the Oil Industry Advisory
Committee 1997 document to include all industries.
• So it is not new.
• Safe isolation should include environmental
protection.
• This is not an ACOP but sets a standard that all
COMAH sites should seek to attain. It represents
‘Good Practice’ and can be enforced.
The Safe Isolation of Plant and
Equipment – HS(G) 253
Legal basis

• HSWA – keeping people safe


• Management Regs – assessing the risk
• PUWER – safety of work equipment Reg 19.
• PSSR – unintentional release of stored energy
• COSHH – exposure to dangerous substances
• Confined spaces Regs – exposure to hazardous
atmosphere
• COMAH – all measures necessary
PUWER Regulation 19

• Every employer shall ensure that where


appropriate work equipment is provided
with suitable means to isolate it from all
its sources of energy.
• Clearly identifiable and readily accessible.
• Risks during reconnection.
• These are all covered by HS(G) 253.
Who has duty?

• COMAH sites - the duty is with the COMAH


operator and cannot be passed on to a
contractor.
• The COMAH operator needs to ensure that the
recommendations in HS(G) 253 are followed as
far as is reasonably practicable.
• The COMAH operator needs to be able to
demonstrate risk is ALARP for each isolation on
site that could lead to a MAH.
Reducing the risk

• Avoid risk wherever possible.


• Engineering not PPE (6 step risk
assessment model - ERIC PD) Eliminate,
Reduce, Isolate, Control, PPE, Discipline.
• If risk is intolerable the work should not go
ahead.
• Opening up any system involves a risk,
isolation is required for a 1/4” pipe as well
as for a 6’ gas main.
• Use CBA to assure ALARP position.
So are all isolations the same?

• A leak from a ¼” gas line may be far more


hazardous than an open end on (say)
water main.
• HS(G) 253 recognises this and allows
each isolation to be assessed differently.
• This ensures that the risks are controlled
and gives a good indication on where the
ALARP solution might lay.
Examples
So why the interest now?

• Recent incidents where poor containment


was a contributory factor.
• Water main.
• Process gas
• Steam
• Refinery Plant
Water Main

• Two men working in a pit with open


ended 2m water main supply line.
• Single valve isolation failed.
• Double fatality as water swirled around
the pit.
• We will see later if the single valve
isolation met HS(G)253 expectations.
Process gas

• Two contractors injured after blast from


burning hydrocarbons in a large open
topped vessel opened for maintenance.
• Isolation by single valve on live inlet and
blank on live outlet. Valve not locked shut.
• Valve opened allowing flammable toxic
gas into vessel.
• Routine operation - so major
maintenance isolation standards were not
followed.
Steam
• Fatality from high pressure steam where
complex isolation failed.
• More than twenty lines fed into the isolated
vessel.
• Isolations were by a number of types of valve,
including control valves.
• Some were locked off, others could not be.
• Control valve operated and released
superheated steam into work area. HSG 253
recommends not to use control valves for
isolations
Toxic & Flammable

• Isolation required for work on process


pipework.
• Complex refinery with miles of piping.
• Isolation identified and fitted to standard.
• Did not check effectiveness of isolation
fully before breaking into pipe.
• Isolation was on the adjacent line.
• Release of toxic and flammable gases,
workers hospitalised.
Mechanical Isolation

Determination of Outcome Factor


baseline isolation
standard – HSG
253 A B C
Substance 1 R I I
Category
2 R I II
3 I II II
4 II II II
5 II III III
Mechanical isolation

• Other isolations are often required – for example


electrical. These are not dealt with today, where
the emphasis is on the safe mechanical isolation
of plant and machinery.
• Mechanical isolation can be achieved in a variety
of ways and today looks at the most appropriate
methods for some generic scenarios using the
tools provided in HS(G) 253.
So why isolate?

• To prevent the loss of containment of


what is in the piping system or the vessel.
• This may be a gas, a liquid or a powder.
• Sometimes you may isolate to stop
something getting in rather than to stop
something getting out.
• Sometimes you may isolate to prevent
mixing of two substances that could react.
So why isolate?

• To allow maintenance or inspection.


• To take a piece of plant out of use for a
short or a longer period.
• To change process streams.
• To ensure that, even on dead plant, a
mistake elsewhere cannot lead to danger.
• Because there is always a potential for
human error or mechanical failure.
• Defence in depth
Basic principles

• Set a policy and standards for isolation –


HSG 253 Appendix 3 gives examples.
• Set procedures with workers help.
• Train all staff – Make contractors aware
and ensure compliance with company
standards and expectations.
• Assess any deviation from standard.
Basic principles

• Set a plan to remedy any deviations.


• Monitor, review and audit isolations –
HSG 253 Appendix 3 gives checklists for
monitoring & review.
• Revise policy, standards and procedures
as required.
• Set KPIs and ensure corporate overview.
Health and Safety
Executive

Thank you

Any questions?

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